Privacy policy

01Who this covers

This policy is published by Limelight International LLC, at 1309 Coffeen Avenue, Ste 2379, Sheridan, WY 82801, United States, trading as Hot Leads at tryhotleads.com. It covers three different groups of people, and they are treated differently.

• People we contact on a client's behalf. If you got a call or a message from us, this is you. You are in a list that one of our clients supplied or asked us to build. The client decided that you should be contacted. We do the contacting, and we keep the record of it.
• People who hold an account. Staff at a client business who log in to see their own campaign, and our own reps and operations staff.
• People who fill in the form on this website. The booking form is the only public form on the site.

The legal characterisation of the first group, meaning which party is the controller of that data and which is the processor, depends on the jurisdiction and is set out in the contract between us and the client: [CONTROLLER AND PROCESSOR CHARACTERISATION, TO BE CONFIRMED BY COUNSEL]. Operationally the position is simple and is stated above: the client chooses who is contacted, and we act on that instruction.

02What we hold about a contacted person

This is the full list of what the product stores about somebody in a client's calling list. It is written from the database schema rather than from memory, so it is what is actually there.

About you

• First name, last name, job title and seniority.
• The URL of your public professional profile, where one was supplied.
• Your city, state and country, and the timezone we resolved from that address. We record how the timezone was resolved, because calling hours are judged in your local time and getting it wrong is a per call violation.

About your employer

• Company name, website domain, public company profile URL, industry and headcount.

Your phone numbers

• Each number in international format, plus the raw text it arrived as and any extension.
• What a carrier lookup said about it: whether it is a mobile, a landline or an internet line, the carrier, and a grade for how likely it is to be answered. Whether a number is a mobile changes which rules apply to calling it, which is why it is stored.
• Whether a message to that number was previously accepted or came back undeliverable, so we stop offering a rep a number that cannot be reached.
• Any do-not-call decision recorded against the number, and when.

Your email addresses

• The address, whether it is a work address, and whether it has been verified. We do not send marketing email to a contacted person from this product.

Working state

• Which campaign you are in, your status in it, how many times you have been attempted, when the last attempt was, and when you become eligible again.
• Anything the client chose to attach to your record as a custom field, and any identifier they use for you in their own systems.

03Calls, recordings and transcripts

When a rep calls you, the product writes a record of the call. That record holds the direction of the call, the number dialled and the number it was dialled from, the times it was queued, rang, was answered and ended, how long it lasted, how long the conversation itself lasted, what the rep marked the outcome as, and any notes the rep typed.

Where the call was recorded, it also holds the audio, the length of the audio, a transcript of it, a short summary, and the time at which the rep confirmed they read the recording disclosure aloud to you.

Recording does not happen everywhere and it is not decided by a rep. Whether a call may be recorded at all, and whether the audio may be kept, is decided per call by the compliance gate against the rules for your state. In a state that requires everyone on the call to consent, no audio is kept unless the rep confirmed they read you the disclosure first. The recording policy sets out the whole of it, including the exact words the rep reads.

We also keep the raw messages our telephony provider sends us about each call. Those arrive out of order and sometimes duplicate, and keeping them verbatim is the only way to reconstruct what happened on a call that went wrong.

04Messages

The product can send and receive messages as a follow up to a call. Where it does, we store the full text of every message in both directions, anything attached to it, which of your numbers it went to, whether it was delivered, whether it was read, and any failure the provider reported. We store the raw provider notifications for the same reason we keep them for calls.

Your replies are read by a person. Inbound messages land in an inbox that a rep works, rather than being classified automatically and filed away.

05Consent and compliance records

Two kinds of record exist purely so that what happened can be proven afterwards, and both are deliberately never deleted.

• Consent records. One row each time consent or its withdrawal is recorded, per channel. Where you asked us to stop, the record holds the exact words you used, verbatim. A paraphrase would be worthless as evidence, which is why it is stored as written. Where a recording disclosure was read to you, the record holds the text that was read.
• Decision records. One row for every attempt to call or message you, whether it went ahead or was refused, including every rule that was evaluated and what it returned. A refusal is kept as carefully as a call, because a refusal is the evidence that the gate was closed.

A do-not-call listing against your number is also a permanent record. It has to be: deleting it is how a number that asked to be left alone gets called again.

06Account holders and site visitors

If you hold an account, we store your name, email address, a profile image URL where one is held, your timezone, your role, and when you were last active. Your password is stored hashed by the authentication library and never in readable form. Each sign-in session stores the IP address and browser user agent it was created from, which is how a session can be recognised and ended.

If you booked a call through this site, we store what you typed into the form: your name, work email, company, website, phone number, roughly how many reps you are looking for, what you sell and how you found us, along with any notes our team adds while working the enquiry. You get a confirmation email and our team gets a notification of it.

Because that form sends email to whatever address is typed into it, it is also protected from being used by scripts. To do that we store a one way keyed hash of the IP address a request came from, which lets us count requests from one connection without keeping the address itself, and the result of an automated check that the request came from a person. A request our filter judges to be automated is kept, marked as such, and sent no email, so that our team can still find and restore it if the filter was wrong.

If you are a client filling in onboarding, we store your answers to the intake questionnaire and who submitted them.

This site does not run third party analytics, advertising pixels or tracking cookies. The only cookie the product sets is the one that keeps you signed in, and it is not readable by scripts.

One thing worth saying because it is easy to miss: the public pages of this site load their typefaces from a third party font host, so that host sees the request your browser makes for them, including your IP address. The signed-in application does not, and serves its own.

The booking form also loads a check, run by a third party, that tells a person apart from a script. That service sees your IP address and information about your browser when the form loads, and we use its answer for nothing except deciding whether to accept the request.

07Where the data comes from

Lead records reach the product by one of five routes.

• A client uploads a file of contacts they already hold.
• A client, or our team on their behalf, enters a contact by hand.
• A client pushes contacts in through the documented API.
• Our team builds a list through a business data enrichment provider, against filters the client specified, such as industry, company size, job title and geography.
• You reply to an email a client sent you through their own outreach tool, and that tool forwards the reply to us so a rep can call you back quickly. This route creates a record for you if you did not already have one, stores the text of your reply as you wrote it, and looks your mobile number up through the enrichment provider if the client does not already hold one. It is the only route where something you sent is what starts the record.

Phone numbers are additionally checked with a carrier lookup so that we know whether a number is live, what kind of line it is, and how likely it is to be answered. That check returns information about the number, not about you.

08Who else it reaches

Hot Leads holds the system of record. A small number of outside services are involved in making a call connect, a message send or a page load, and each of them sees only what that job requires.

We describe them by category rather than by name. Naming our suppliers in public copy is against our own house rule, and it also tells a competitor how the floor is built. The full named list, and the contract terms we hold each of them to, is available on request from nooruddin@sellmysaas.io, to anybody whose data is involved.

• Telephony provider. Connects the call. Sees the number being dialled, the number it is dialled from, and the audio of the call.
• Messaging provider. Sends and receives messages. Sees the number and the message content.
• Data enrichment provider. Supplies business contact records and carrier information about a phone number, where a client asked us to build a list.
• Transcription provider. Turns a call recording we hold into text. Receives the audio of recorded calls only.
• Object storage host. Stores call recordings.
• Database host. Runs the database everything above is written to.
• Email provider. Sends account email such as invitations. Sees the recipient address and the message. It is not used to email contacted people.
• Application hosting provider. Serves this website and the application.
• Bot protection service. Checks that a request sent through the booking form came from a person. Sees the visitor's IP address and information about their browser.

Separately, and only where a client sets it up, the product can write campaign activity into that client's own customer relationship system, and can receive replies from the outreach tools that client already uses. Those are the client's systems and the client's choice, and data sent to them is governed by the client's own policies from that point.

We do not sell personal data, and we do not share it with anyone for their own marketing.

09Do Not Call, stated plainly

The same is true of state registries and of litigator lists. All three are recorded as not checked. When a licensed scrub is connected, those records will start saying whichever of clear or listed is true, and this paragraph will be replaced rather than quietly dropped.

What does run on every outbound call, today:

• Our own do-not-call list. If you have asked us or the client to stop, the call is refused.
• Calling hours in your local time, resolved from your address rather than your area code, and narrowed to whichever of the federal window, the state window and the campaign window is tightest.
• An attempt cap and a cooldown set by the campaign, so a number is not dialled repeatedly.
• A recording decision for your state, described in the recording policy.

10How long it is kept

Nothing in this product deletes your data on a schedule today. There is no retention job, no expiry and no automatic purge. Leads, calls, recordings, transcripts, messages, consent records and decision records are kept until somebody removes them deliberately. We are telling you this rather than publishing a retention period we do not enforce.

Where a record is archived in the product, it is hidden from the screens that use it and the row is kept, because a client may hold a report that refers to it.

One more thing worth saying exactly. When a call is recorded, the telephony provider makes its own copy and we then copy it into our storage. Where our compliance rules mean we must not keep the audio, we do not copy it, and today we do not ask the provider to delete their copy either. That is a gap we know about. It is described here rather than papered over, and closing it is on the work list.

Setting and enforcing a retention period is a decision for the business rather than something to guess at in a policy page: [RETENTION PERIOD, ONCE DECIDED AND IMPLEMENTED].

11Your rights, and how to use them

Which rights you have depends on where you live, not on where we are. Our agreements with clients are governed by Wyoming law, but that has no bearing on this: if you are in California, or Colorado, or Connecticut, or any of the other states that have passed a consumer privacy act, your rights come from your own state and we will honour them there. Nothing on this page asks you to accept a different jurisdiction as the price of exercising them.

What follows is what we will do on request, regardless of where you are and regardless of whether a statute in your state compels it.

• Tell you what we hold about you. Everything in clauses 02 to 05, as it stands on the day you ask.
• Tell you which client's list you are on, so you can go to them as well if you want to.
• Correct anything that is wrong. A lot of business contact data is stale and some of it was never right.
• Stop contacting you. See clause 12. This one is immediate and does not require us to agree with you.
• Delete a call recording. There is no self service control for this today, so it is a manual request to the address below.

Requests go to nooruddin@sellmysaas.io. We will not ask you to create an account to make one. If you were contacted by us, tell us the number we called and we can find you from that.

One limit, stated honestly: if you ask us to erase everything, we will keep the record of your do-not-call request and the decision records attached to it. Deleting the evidence that you asked us to stop is how you get called again by the next import, and the record of a refused call is what protects you rather than us.

12Asking us to stop

You can tell us to stop in a reply to a message, or by telling the rep on a call, or by writing to nooruddin@sellmysaas.io. All three work, but they do not all work the same way, and you should know which is which.

• A reply to a message is scanned automatically. The scan looks for the usual words and phrasings rather than any possible wording, so if it does not recognise what you wrote, the thread still goes to a person who reads it and records the request by hand.
• Telling the rep on a call is recorded by the rep when they write up the call. It is a person acting on what you said, not an automatic step.
• Writing to us reaches a person, not a system. There is nothing automatic on this route at all, and it is the slowest of the three.

Once the request is recorded, by whichever route, five things happen at once.

• Your words are stored verbatim as the evidence.
• The conversation is closed. The reply box is replaced by a notice and nothing further can be sent on that thread.
• You are marked as suppressed, which takes you out of the dialling queue so no rep is offered your record.
• Every phone number on your record is added to our internal do-not-call list, which the compliance gate checks before every single call.
• It is applied to every channel at once, not only the one you used. Somebody who says stop in a message has not said keep calling me.

None of this is reversible from inside the product. There is no screen anywhere that undoes it, and there should not be. A recorded request to stop is not something a rep gets to click away.

13How it is separated and protected

Each client sees only their own data. Today that is enforced in the application: reading a tenant table without declaring whose data you are reading does not compile, and every query carries the client it was made for. The database holds a matching policy on every tenant table, written to be the second line of defence, but the account the application connects with is currently permitted to bypass those policies, so the protection resting on them is the application layer rather than the database. We are changing that. We would rather say which of the two is load bearing than claim both and leave you to assume.

Our own staff can see the data of the clients they run campaigns for. That is what a managed service is. What a client can see never includes another client, and it never includes our internal cost figures.

Passwords are stored hashed. Incoming notifications from our telephony and messaging providers are signature checked, and an unverifiable one is rejected rather than trusted, because an unverifiable notification and a forged one look identical and that endpoint writes call records.

We do not hold any security certification, and we are not going to imply one. If you need a specific attestation, ask and we will tell you plainly whether we have it.

14Changes and contact

When this page changes materially we will change the effective date at the top and keep the previous version available on request. We will not change it silently to describe something the product started doing.

Privacy questions, requests and complaints go to nooruddin@sellmysaas.io, or by post to 1309 Coffeen Avenue, Ste 2379, Sheridan, WY 82801, United States. We have not appointed a data protection officer, and we are not going to name one who does not exist.

This policy sits alongside our terms of service and our recording policy.